Unreported / Non-Citable
Background
Jose Alvaro Aranda Molina, a Mexican citizen, entered the United States without inspection in 2021. After immigration authorities encountered him at the McLennan County Jail in July 2026, they took him into custody and served him with a notice to appear charging him as inadmissible under 8 U.S.C. § 1182(a)(6)(A)(i). He remained detained while removal proceedings were pending.
Aranda Molina petitioned for habeas relief under 28 U.S.C. § 2241 and sought preliminary injunctive relief, arguing that detention without a bond hearing violated the Immigration and Nationality Act, due process, the Administrative Procedure Act, and the Central District of California’s Bautista v. Santacruz rulings. The respondents moved for summary judgment, contending that 8 U.S.C. § 1225(b)(2) required his detention as an applicant for admission.
The Court’s Holding
The court held that Aranda Molina’s presence in the United States without admission made him an applicant for admission subject to mandatory detention under § 1225(b)(2). Relying on the Fifth Circuit’s decision in Buenrostro-Mendez v. Bondi, the court concluded that the statute applies even when a noncitizen was already present in the country at the time of arrest.
The court further held that mandatory detention during Aranda Molina’s removal proceedings did not violate substantive or procedural due process. It declined to apply the California district court’s Bautista rulings because they did not control in light of binding Fifth Circuit precedent, and it concluded that his APA claim was foreclosed. The court granted the respondents’ motion for summary judgment, denied the habeas petition and request for preliminary injunctive relief, and directed entry of final judgment for the respondents.
Key Takeaways
- A person present in the United States without having been admitted may be treated as an applicant for admission and detained under 8 U.S.C. § 1225(b)(2).
- Under controlling Fifth Circuit precedent, § 1225(b)(2) applies even when immigration authorities arrest the person after the person has already entered the country.
- The court rejected statutory, due-process, and APA challenges to detention without a bond hearing and declined to follow contrary California district-court rulings.
Why It Matters
The ruling applies the Fifth Circuit’s interpretation of § 1225(b)(2) to deny bond-hearing claims by noncitizens who entered without inspection and were later arrested inside the United States. It confirms that, within the Fifth Circuit, such detainees may be held as applicants for admission while the proceedings specified by Congress remain pending.
The decision also illustrates that the Bautista litigation in the Central District of California does not displace contrary binding circuit precedent in Texas federal courts.